Georgia is strengthening its regulatory framework on Transfer Pricing with new reporting requirements set to take effect in 2026. These measures aim to increase transparency in cross-border transactions and provide the tax authority with more structured information to identify potential transfer pricing risks.
Georgia is strengthening its Transfer Pricing regulatory framework with new reporting requirements that will take effect in 2026. These measures aim to increase transparency in cross-border transactions and provide the tax authority with more structured information to detect potential Transfer Pricing risks.
The reform reflects a broader international trend in which tax administrations are seeking greater visibility into the activities of multinational groups and intra-group transactions.
New Reporting Requirements
The new obligation stems from amendments introduced on February 24, 2026, to Order No. 996 of the Minister of Finance of Georgia. Under these amendments, Georgian companies and Georgian permanent establishments involved in internationally controlled transactions must file additional information with the Georgian Tax Service as part of their corporate income tax return.
Companies operating under Georgia’s “Estonian model” corporate income tax regime must file a specific annex titled “Information on International Controlled Transactions” along with their corporate income tax return filed in March.
This obligation applies when the total value of international controlled transactions exceeds Georgian Lari (GEL) 500.000 during the corresponding fiscal year. The threshold does not only include direct transactions, but also pending balances related to controlled transactions, such as accounts receivable and payable. Transactions conducted without consideration or through barter agreements must also be contemplated when determining whether the threshold has been exceeded.
The deadline for filing Transfer Pricing information with the Georgia Tax Service is April 15, 2026.
Scope of Controlled Transactions
Under Georgia’s Transfer Pricing framework, international controlled transactions include cross-border related party transactions or transactions involving entities located in tax havens.
These transactions may involve the purchase or sale of goods, the provision or receipt of services, or financial transactions such as intra-group loans, royalty payments, or other commercial related-party agreements. If the combined value of such transactions exceeded 500,000 GEL during the 2025 fiscal year, the Georgian company or permanent establishment must disclose detailed information in its March 2026 corporate income tax return.
Companies must also indicate whether Transfer Pricing documentation has been prepared. This requirement enables the tax authority to assess whether the company has conducted an analysis supporting the arm’s length nature of its transactions.
Implications for Companies
The introduction of the reporting obligation should enhance the skills of the Georgian tax authority to identify companies involved in substantial cross-border transactions, potentially leading to increased Transfer Pricing scrutiny. With better access to structured information, tax administration will be able to identify potential risks more effectively and prioritize cases for detailed review.
For businesses, this amendment highlights the importance of reviewing Transfer Pricing policies and ensuring that appropriate documentation is in place. Preparing Transfer Pricing documentation in advance can significantly reduce potential tax risks during audits and support compliance with the Arm’s Length Principle.
Conclusion
Introducing the Transfer Pricing reporting requirement in Georgia is a crucial step toward enhancing tax transparency and oversight of internationally controlled transactions. As regulatory scrutiny increases, companies operating in Georgia should proactively review their Transfer Pricing policies and ensure accurate documentation.
TPC Group supports multinational organizations in analyzing their cross-border transactions, preparing Transfer Pricing documentation, and adapting to constantly evolving international tax compliance requirements.
Source: Forbes Georgia